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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`REACTIVE SURFACES LTD., LLP
`
`Petitioner
`
`v.
`
`TOYOTA MOTOR CORPORATION
`
`Patent Owner
`
`
`
`CASE: IPR2016-01462
`
`Patent No. 8,324,295 B2
`
`
`
`PETITIONER’S NOTICE OF DEPOSITION OF
`
`ROBERT IEZZI, PH.D.
`
`
`
`

`

`
`
`
`
`
`
`Please take notice, pursuant to 37 C.F.R. § 42.53(d)(4), that counsel for
`
`IPR2016-01462
`U.S. Patent No. 8,324,295 B2
`
`Petitioner will conduct cross-examination by deposition of Patent Owner’s declarant
`
`Dr. Robert Iezzi. As agreed to by counsel for the parties pursuant to 37 C.F.R. §
`
`42.53(d)(1), the deposition will take place on July 12, 2017 at the offices of
`
`Dinsmore & Shohl, LLP, 255 East Fifth Street, Suite 1900, Cincinnati, OH 45202,
`
`before an officer authorized to administer oaths. The deposition will commence at
`
`9:00 am (CST). The deposition will be recorded by stenographic means and
`
`videotaped. Further, in addition to counsel for Petitioner conducting such cross-
`
`examination in-person at the above-mentioned location, counsel for Petitioner may
`
`also be using a video, audio, and/or real-time stenographic feed that will allow
`
`members of Petitioner’s counsel not attending the deposition in-person to attend the
`
`deposition from a remote location.
`
`NOTICE IS FURTHER GIVEN that the deponent shall bring and produce
`
`at the deposition, at the time and place specified in this notice, the documents and
`
`writings (as “writing” is defined in Federal Rules of Evidence Rule 1001),
`
`described in Exhibit “A” hereto.
`
`Dated: June 7, 2017
`
`
`
`Respectfully submitted,
`
`By:
`
`/s/ David O. Simmons
`
`David O. Simmons, Reg. No. 43,124
`
`2
`
`
`
`
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Jonathan D. Hurt
` Jonathan D. Hurt, Reg. No. 44,790
`
`Counsel for Petitioner, Reactive
`Surfaces LTD., LLP
`
`
`
`3
`
`

`

`CERTIFICATE OF SERVICE
`
`Pursuant to 37 CFR §§ 42.6(e)(4)(i) and 42.105(b), the undersigned hereby
`
`certifies that a copy of this Petitioner’s Notice of Deposition of Robert Iezzi, Ph. D
`
`for inter partes review of U.S. Patent No. 8,324,295 was served on June 7, 2017 by
`
`email on the following counsel of record for Patent Owner:
`
`Joshua A. Lorenz (joshua.lorentz@dinsmore.com)
`
`Richard H. Schabowsky (richard.schabowsky@dinsmore.com)
`
`John D. Luken (john.luken@dinsmore.com)
`
`Oleg Khariton (oleg.khariton@dinsmore.com)
`
`
`
`/s/ David O. Simmons
`
`David O. Simmons, Reg. No. 43.124
`Lead Counsel
`
`Email: dsimmons@ivcpatentagency.com
`
`Counsel for Petitioner, Reactive
`Surfaces LTD., LLP
`
`
`
`4
`
`
`
`
`
`
`
`

`

`
`
`EXHIBIT A
`SUBPOENA DUCES TECUM
`
`
`1. Any and all documents and/or materials reviewed, relied on, and/or
`considered in formulating his/her opinions offered within his/her expert
`declaration.
`
`
`
`
`
`5
`
`

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